Privacy Policy

This Privacy Policy sets out how we, CtrlShift Singapore Pte Ltd, collect, store and use information about you when you use or interact with our website, https://www.ctrlshift.com (our website) and where we otherwise obtain or collect information about you. This Privacy Policy is effective from 1 January  2019.

 

Contents

  • Summary
  • Our details
  • Information we collect when you visit our website
  • Information we collect when you contact us
  • Disclosure and additional uses of your information
  • How long we retain your information
  • How we secure your information
  • Transfers of your information outside the European Economic Area
  • Your rights in relation to your information
  • Your right to object to the processing of your information for certain purposes
  • Sensitive Personal Information
  • Changes to our Privacy Policy
  • Children’s Privacy
  • Copyright, credit and logo

 

Summary

This section summarises how we obtain, store and use information about you. It is intended to provide a very general overview only. It is not complete in and of itself and it must be read in conjunction with the corresponding full sections of this Privacy Policy.

  • Data controller: CtrlShift Singapore Ptd Ltd
  • How we collect or obtain information about you:
    • when you provide it to us (e.g. by contacting us)
  • Information we collect: Name, email, company name, job title, IP address, information from cookies, information about your computer or device (e.g. device and browser type), information about how you use our website (e.g. which pages you have viewed, the time when you view them and what you clicked on, the geographical location from which you accessed our website (based on your IP address).
  • How we use your information: for administrative and business purposes particularly to contact,to improve our business and website, to advertise our goods and services, to analyse your use of our website, and in connection with our legal rights and obligations.
  • Disclosure of your information to third parties: only to the extent necessary to run our business, to our service providers, to fulfil any contracts we enter into with you, where required by law or to enforce our legal rights.
  • Do we sell your information to third parties (other than in the course of a business sale or purchase or similar event): No
  • How long we retain your information: for no longer than necessary, taking into account any legal obligations we have (e.g. to maintain records for tax purposes), any other legal basis we have for using your information (e.g. your consent, performance of a contract with you or our legitimate interests as a business). For specific retention periods in relation to certain information which we collect from you, please see the main section below entitled How long we retain your information.
  • How we secure your information: using appropriate technical and organisational measures such as storing your information on secure servers, encrypting transfers of data to or from our servers using Secure Sockets Layer (SSL) technology, only granting access to your information where necessary and ensuring that all public access to our servers is unavailable, specific to the data and/or logs pertaining to this information.
  • Transfers of your information outside the European Economic Area: Our current data centers are in Singapore stored in a globally used public cloud based system that provides necessary security options to ensure that data, while outside the EU, remains protected. Please check https://aws.amazon.com/compliance/eu-us-privacy-shield-faq/ for additional information on EU Privacy Shield protection.
  • Sensitive personal information: we do not knowingly or intentionally collect what is commonly referred to as ‘sensitive personal information’. Please do not submit sensitive personal information about you to us. For more information, please see the main section below entitled Sensitive Personal Information.

 

Our details

The data controller in respect of our website is The Studio by CtrlShift Pte Ltd of 21 Media Circle, #06-01, Infinite Studios, 138562, Singapore. You can contact the data controller by sending an email to marketing@ctrlshift.com.

If you have any questions about this Privacy Policy, please contact the data controller.

 

Information we collect when you visit our website

We collect and use information from website visitors in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Web  information

We use a Amazon Web Services to host our website, the privacy policy of which is available here: https://aws.amazon.com/privacy/. Our website server may automatically record the IP address and other parts of the browsers user agent, this may include the browser type, the OS version and timestamp

Use of website server log information for IT security purposes

 

We AND/OR our third party hosting provider collect(s) and store(s) server logs to ensure network and IT security and so that the server and website remain uncompromised. This includes analysing log files to help identify and prevent unauthorised access to our network, the distribution of malicious code, denial of services attacks and other cyber attacks, by detecting unusual or suspicious activity.

Unless legally required, we do not anticipate any reason to identify the IP address collected automatically in the web server logs

Legal basis for processing: compliance with a legal obligation to which we are subject

Legal obligation: we have a legal obligation to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk of our processing of information about individuals. Recording access to our website using server log files is such a measure.

Legal basis for processing: our and a third party’slegitimate interests

Legitimate interests: we and our third party hosting provider have a legitimate interest in using your information for the purposes of ensuring network and information security.

Use of website server log information to analyse website use and improve our website

We may use the information collected by our website server logs to analyse how our website users interact with our website and its features. For example, we may analyse the number of visits and unique visitors we receive, the time and date of the visit, the location of the visit and the operating system and browser used.

We may use the information gathered from the analysis of this information to improve our website. For example, we use the information gathered to change the information, content and structure of our website and individual pages based according to what users are engaging most with and the duration of time spent on particular pages on our website.

Legal basis for processing: our legitimate interests

Legitimate interest: improving our website for our website users and getting to know our website users’ preferences so our website can better meet their needs and desires.

 

Cookies and similar technologies

We use cookies and similar information-gathering technologies on our website. For more information, please visit our cookies policy here: https://ctrlshift.com/cookies-policy/

 

You can reject some or all of the cookies we use on or via our website by changing your browser settings, but doing so can impair your ability to use our website or some or all of its features.

For further information about cookies, including how to change your browser settings, please visit www.allaboutcookies.org or see our cookies policy.

 

Information we collect when you contact us

We collect and use information from individuals who contact us in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Email

When you send an email to the email address displayed on our website we collect your email address and any other information you provide in that email (such as your name, telephone number and the information contained in any signature block in your email).

Legal basis for processing: our legitimate interests

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services for example, providing you with information about such goods and services, we will process your information in order to do so.

 

Transfer and storage of your information

We use a third party email provider to store emails you send us. Our third party email provider is Google gmail. Their privacy policy is available here: : https://policies.google.com/privacy?hl=en.

 

Emails you send us will be stored [within OR outside] the European Economic Area on our third party email provider’s servers. For further information please see the section of this privacy policy entitled Transfers of your information outside the European Economic Area.

 

Contact form

When you contact us using our contact form, we collect names, email, company name and job title.

If you do not provide the mandatory information required by our contact form, you will not be able to submit the contact form and we will not receive your enquiry.

If you do not supply the optional information required by our contact form, such as your reasons for contacting us, we may not be able to respond with relevant information or service required.

Legal basis for processing: our legitimate interests

Legitimate interest(s): responding to enquiries and messages we receive and keeping records of correspondence.

Legal basis for processing: necessary to perform a contract or to take steps at your request to enter into a contract.

Reason why necessary to perform a contract: where your message relates to us providing you with goods or services or taking steps at your request prior to providing you with our goods and services (for example, providing you with information about such goods and services), we will process your information in order to do so).

 

Transfer and storage of your information

We use a third party contact form provider to store messages you send us. Our contact form provider is HubSpot Inc. Their privacy policy is available here: https://legal.hubspot.com/privacy-policy. Messages you send to us via our contact form will be stored within OR outside the European Economic Area on our contact form provider’s servers.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Information we collect when you interact with our website

We collect and use information from individuals who interact with particular features of our website in accordance with this section and the section entitled Disclosure and additional uses of your information.

 

Disclosure and additional uses of your information

This section sets out the circumstances in which will disclose information about you to third parties and any additional purposes for which we use your information.

 

Disclosure of your information to service providers

We use a number of third parties to provide us with services which are necessary to run our business or to assist us with running our business and who process your information for us on our behalf. These include the following:

  • Email providers, including Google Inc. and HubSpot Inc.Their privacy policies are available via these links:

https://www.google.com/policies/privacy/ and https://legal.hubspot.com/privacy-policy

  • Hosting provider, Amazon Web Services, Inc. Their privacy policy is available here: https://aws.amazon.com/privacy/

Your information will be shared with these service providers where necessary to provide you with the service you have requested, whether that is accessing our website or ordering goods and services from us.

We do not display the identities of all of our service providers publicly by name for security and competitive reasons. If you would like further information about the identities of our service providers, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such service providers, for example).

Legal basis for processing: legitimate interests

Legitimate interest relied on: where we share your information with these third parties in a context other than where is necessary to perform a contract (or take steps at your request to do so), we will share your information with such third parties in order to allow us to run and manage our business efficiently.

Legal basis for processing: necessary to perform a contract and/or to take steps at your request prior to entering into a contract.

Reason why necessary to perform a contract: we may need to share information with our service providers to enable us to perform our obligations under that contract or to take the steps you have requested before we enter into a contract with you.

 

Disclosure of your information to other third parties

We disclose your information to other third parties in specific circumstances, as set out below.

Google collects information through our use of Google Analytics on our website. Google uses this information, including IP addresses and information from cookies, for a number of purposes, such as improving its Google Analytics service. Information is shared with Google on an aggregated and anonymised basis. To find out more about what information Google collects, how it uses this information and how to control the information sent to Google, please see the following page: https://www.google.com/policies/privacy/partners/

 

Legal basis for processing: our legitimate interests.

Legitimate interest(s): meeting our contractual obligations to Google under our Google Analytics Terms of Service (https://www.google.com/analytics/terms/us.html)

You can opt out of Google Analytics by installing the browser plugin here: https://tools.google.com/dlpage/gaoptout

 

Transfer and storage of your information

Information collected by Google Analytics is stored outside the European Economic Area on Google’s servers in the United States of America.

For further information about the safeguards used when your information is transferred outside the European Economic Area, see the section of this privacy policy below entitled Transfers of your information outside the European Economic Area.

 

Sharing your information with third parties, which are either related to or associated with the   running of our business, where it is necessary for us to do so. These third parties include our affliates. Further information on each of these third parties is set out below.

Legal basis for processing: our legitimate interests

Legitimate interest: running and managing our business efficiently.

 

Affiliates

Affiliates are individuals or entities we work with to promote our business by various means, including by advertising our services on their websites, for example. Affiliates will share information with us and we will share information with them where you have expressed an interest in our products or services.

Our affiliates are CtrlShift Singapore Pte Ltd Pte Ltd, CtrlShift Holdings UK Ltd, The Studio By CtrlShift Pte Ltd, The Studio By CtrlShift Sdn Bhd, CtrlShift Malaysia Sdn Bhd (MY), CtrlShift (Thailand) Co Ltd and Asia Digital Ventures Pte Ltd.

 

 

 

Legal basis for processing: our legitimate interests

Legitimate interest: running and managing our business effectively.

AND/OR

Legal basis for processing: necessary to perform a contract or to take steps at your request prior to entering into a contract.

Reason why necessary to perform a contract: we need to share your information with other companies in order to be able to meet our contractual obligations to you or to take steps at your request prior to entering a contract, for example because of the services or information you have requested.

We do not display the identities of all of the other third parties we may share information with by name for security and competitive reasons. If you would like further information about the identities of such third parties, however, please contact us directly via our contact form or by email and we will provide you with such information where you have a legitimate reason for requesting it (where we have shared your information with such third parties, for example).

 

 

 

Disclosure and use of your information for legal reasons

 

Indicating possible criminal acts or threats to public security to a competent authority

If we suspect that criminal or potential criminal conduct has occurred, we will in certain circumstances need to contact an appropriate authority, such as the police. This could be the case, for instance, if we suspect that fraud or a cyber crime has been committed or if we receive threats or malicious communications towards us or third parties.

We will generally only need to process your information for this purpose if you were involved or affected by such an incident in some way.

Legal basis for processing: our legitimate interests

Legitimate interests: preventing crime or suspected criminal activity (such as fraud).

 

In connection with the enforcement or potential enforcement our legal rights

We will use your information in connection with the enforcement or potential enforcement of our legal rights, including, for example, sharing information with debt collection agencies if you do not pay amounts owed to us when you are contractually obliged to do so. Our legal rights may be contractual (where we have entered into a contract with you) or non-contractual (such as legal rights that we have under copyright law or tort law).

Legal basis for processing: our legitimate interests

Legitimate interest: enforcing our legal rights and taking steps to enforce our legal rights.

 

In connection with a legal or potential legal dispute or proceedings

We may need to use your information if we are involved in a dispute with you or a third party for example, either to resolve the dispute or as part of any mediation, arbitration or court resolution or similar process.

Legal basis for processing: our legitimate interests

Legitimate interest(s): resolving disputes and potential disputes.

 

For ongoing compliance with laws, regulations and other legal requirements

We will use and process your information in order to comply with legal obligations to which we are subject. For example, we may need to disclose your information pursuant to a court order or subpoena if we receive one.

Legal basis for processing: compliance with a legal obligation

Legal obligation(s): legal obligations to disclose information which are part of the laws of Singapore

Legal basis for processing: our legitimate interests

Legitimate interest: where the legal obligations are part of the laws of another country, we have a legitimate interest in complying with these obligations.

 

How long we retain your information

This section sets out how long we retain your information. We have set out specific retention periods where possible. Where that has not been possible, we have set out the criteria we use to determine the retention period.

 

Retention periods

Server log information: we retain information on our server logs for six (3) months.

Correspondence and enquiries: when you make an enquiry or correspond with us for any reason, whether by email or via our contact form,we will retain your information for as long as it takes to respond to and resolve your enquiry, and for seven (7) year(s), after which point we will delete your information.

 

Criteria for determining retention periods

In any other circumstances, we will retain your information for no longer than necessary, taking into account the following:

  • the purpose(s) and use of your information both now and in the future (such as whether it is necessary to continue to store that information in order to continue to perform our obligations under a contract with you or to contact you in the future);
  • whether we have any legal obligation to continue to process your information (such as any record-keeping obligations imposed by relevant law or regulation);
  • whether we have any legal basis to continue to process your information (such as your consent);
  • how valuable your information is (both now and in the future);
  • any relevant agreed industry practices on how long information should be retained;
  • the levels of risk, cost and liability involved with us continuing to hold the information;
  • how hard it is to ensure that the information can be kept up to date and accurate; and
  • any relevant surrounding circumstances (such as the nature and status of our relationship with you).

 

How we secure your information

We take appropriate technical and organisational measures to secure your information and to protect it against unauthorised or unlawful use and accidental loss or destruction, including:

  • only sharing and providing access to your information to the minimum extent necessary, subject to confidentiality restrictions where appropriate, and on an anonymised basis wherever possible;
  • using secure servers to store your information;
  • verifying the identity of any individual who requests access to information prior to granting them access to information;
  • using Secure Sockets Layer (SSL) software to encrypt any information you submit to us via any forms on our website;
  • only transferring your information via closed system or encrypted data transfers.

 

Transmission of information to us by email

Transmission of information over the internet is not entirely secure, and if you submit any information to us over the internet (whether by email, via our website or any other means), you do so entirely at your own risk.

We cannot be responsible for any costs, expenses, loss of profits, harm to reputation, damages, liabilities or any other form of loss or damage suffered by you as a result of your decision to transmit information to us by such means.

 

Transfers of your information outside the European Economic Area

Your information will be transferred and stored outside the European Economic Area (EEA) in the circumstances set out below. We will also transfer your information outside the EEA or to an international organisation in order to comply with legal obligations to which we are subject (compliance with a court order, for example). Where we are required to do so, we will ensure appropriate safeguards and protections are in place.

 

Server log information

[Information collected when you visit our website is transferred outside of the EEA and stored on the servers of our third party hosting company,  Amazon Web Services, Inc. Their privacy policy is available here: https://aws.amazon.com/privacy/

 

Contact form

[Information you submit to us via our contact form is transferred outside the EEA and stored on our third party provider’s servers. Our provider is HubSpot Inc. Their privacy policy is available here: https://legal.hubspot.com/privacy-policy.

 

 

Email

[Information you submit to us by email is transferred outside the EEA and stored on our third party email provider’s servers. Our third party email provider is Google. You can access their privacy policy here: https://www.google.com/policies/privacy/

 

 

Google Analytics

Information collected by Google Analytics (your IP address and actions you take in relation to our website) is transferred outside the EEA and stored on Google’s servers. You can access Google’s privacy policy here: https://www.google.com/policies/privacy/

Country of storage: United States of America. This country is not subject to an adequacy decision by the European Commission.

Safeguard(s) used: Google has self-certified its compliance with the EU-U.S. Privacy Shield which is available here: https://www.privacyshield.gov/welcome. The EU-U.S. Privacy Shield is an approved certification mechanism under Article 42 of the General Data Protection Regulation, which is permitted under Article 46(2)(f) of the General Data Protection Regulation. You can access the European Commission decision on the adequacy of the EU-U.S. Privacy Shield here: http://ec.europa.eu/justice/data-protection/international-transfers/adequacy/index_en.htm

 

Your rights in relation to your information

Subject to certain limitations on certain rights, you have the following rights in relation to your information, which you can exercise by sending an email to marketing@ctrlshift.com:

  • to request access to your information and information related to our use and processing of your information;
  • to request the correction or deletion of your information;
  • to request that we restrict our use of your information;
  • to receive information which you have provided to us in a structured, commonly used and machine-readable format (e.g. a CSV file) and the right to have that information transferred to another data controller (including a third party data controller);
  • to object to the processing of your information for certain purposes (for further information, see the section below entitled Your right to object to the processing of your information for certain purposes); and
  • to withdraw your consent to our use of your information at any time where we rely on your consent to use or process that information. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information on the basis of your consent before the point in time when you withdraw your consent.
  • the right not to be subject to a decision based solely on automated processing, including profiling which produces legal affects concerning you or similarly significantly affects you

Verifying your identity where you request access to your information

Where you request access to your information, we are required by law to use all reasonable measures to verify your identity before doing so.

These measures are designed to protect your information and to reduce the risk of identity fraud, identity theft or general unauthorised access to your information.

 

How we verify your identity

Where we possess appropriate information about you on file, we will attempt to verify your identity using that information.

If it is not possible to identity you from such information, or if we have insufficient information about you, we may require original or certified copies of certain documentation in order to be able to verify your identity before we are able to provide you with access to your information.

We will be able to confirm the precise information we require to verify your identity in your specific circumstances if and when you make such a request.

 

Your right to object to the processing of your information for certain purposes

You have the following rights in relation to your information, which you may exercise in the same way as you may exercise by writing to CtrlShift Singapore Pte Ltd Pte Ltd, 21 Media Circle, #06-01 Infinite Studios, Singapore 138562 or sending an email to marketing@ctrlshift.com

  • to object to us using or processing your information where we use or process it in order to carry out a task in the public interest or for our legitimate interests, including ‘profiling’ (i.e. analysing or predicting your behaviour based on your information) based on any of these purposes; and
  • to object to us using or processing your information for direct marketing purposes (including any profiling we engage in that is related to such direct marketing).

You may also exercise your right to object to us using or processing your information for direct marketing purposes by:

  • clicking the unsubscribe link contained at the bottom of any marketing email we send to you and following the instructions which appear in your browser following your clicking on that link;
  • sending an email to marketing@ctrlsift.com, asking that we stop sending you marketing communications or by including the words “OPT OUT”.

 

Changes to our Privacy Policy

We update and amend our Privacy Policy from time to time.

 

Minor changes to our Privacy Policy

Where we make minor changes to our Privacy Policy, we will update our Privacy Policy with a new effective date stated at the beginning of it. Our processing of your information will be governed by the practices set out in that new version of the Privacy Policy from its effective date onwards.

 

Major changes to our Privacy Policy or the purposes for which we process your information

Where we make major changes to our Privacy Policy or intend to use your information for a new purpose or a different purpose than the purposes for which we originally collected it, we will notify you by email (where possible) or by posting a notice on our website.

We will provide you with the information about the change in question and the purpose and any other relevant information before we use your information for that new purpose.

Wherever required, we will obtain your prior consent before using your information for a purpose that is different from the purposes for which we originally collected it.

 

Copyright, credit and logo

The copyright in this Privacy Policy is either owned by, or licensed to, us and is protected by copyright laws around the world and copyright protection software. All intellectual property rights in this document are reserved.

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